Appendix H-2: Comment letters from Tribes, Federal, State, and local

agencies and elected officials to the Draft EIS

Per Forest Service Handbook 1909.15, Chapter 24.1(3), copies of comment letters received from Tribes,

Federal, State and local agencies and elected officials are included here and are titled Appendix H-2 of

the FEIS.

To Whom It May Concern:

Comments regarding the Spruce Beetle Epidemic - Aspen Decline Management Response EIS

The SBEADMR draft environmental impact statement proposes a proactive 8-12 year approach to move the Grand Mesa,

Uncompahgre, and Gunnison National Forests (GMUG) to a healthier natural state, enabling the use of dead timber while the

timber still has a market value. The citizens of the Montrose community are aware of the need for a healthier forest from multiple

standpoints including recreation, public safety and socioeconomic impact - jobs.

While supporting the timbering of species of spruce/fir we would also like consideration on aspen management and possible

timbering if a market can be developed.

We ask for improved protection of people and infrastructure, capacity to implement the maximum number of resiliency

treatments available to improve the overall long-term health of the forest, and establish essential timber supply to our local timber

industry and the significant number of jobs it generates throughout our community.

We would like support for the unquantifiable benefits such as decreased threat to life, property, water supply and quality, as well

as values such as habitat improvement. Our community is primarily dependent on agriculture (including timbering) and

recreation. Healthy forests are essential to us both economically and for our preferred quality of life.

City of Montrose

P.O. Box 790

Montrose, Colorado 81402

COLORADO PARKS & WILDLIFE

Northwest Regional Service Center

711 Independent Ave. , Grand Junction, CO 81505

Phone (970)255-6100 • FAX (970)255-6111

wildlife.state.co.us • parks.state.co.us

September 10, 2013

Scott Armentrout

Forest Supervisor

2250 Highway 50

Delta, CO 814)6

RE: Colorado Parks and Wildlife Scoping Comments for Spruce Beetle Epidemic

and Aspen Decline Management Response Project (SBEADMR Project)

Colorado Park and Wildlife (CPW) appreciates the opportunity to be involved with the

Grand Me a, Uncompahgre, and Gunnis on National Forest in the scoping process for the

s pruce beetle epidemic and aspen decline management respons e project. The project

planning area landscapes and associated wildlife habitat, natural resource, and s ocio­

economic value are of utmost importance to CPW and the people of the state of Colorado.

CPW is intrigued by the concept of a single tiered Environmental Impact Statement

analys is and its purpose of streamlining the environmental review process and

creating more timely and effective, on-the-ground fores t health project. It is worth

noting, however, that this novel approach is largely untested, with many unknowns, and

CPW requests that the Forest Service use conservative parameters in implementing this

concept. CPW requests that the Forest Service coordinate closely and involve CPW staff

at the project review level and at site visits.

CPW offers the following scoping comments, recommendations, and support for the

SBEADMR Project.

AQUATIC CONSIDERATIONS

Native Fish Species, Riparian Areas, and Aquatic Resources

Native fish species and their habitat require special management action to avoid habitat

degradation or loss. Occupied native f i sh habitat exist within the project area for

Colorado River cutthroat trout (CRCT), Colorado Greenback cutthroat trout (GBCT or

Lineage GB), a Federal and s t ate-listed Threatened Species, roundtail chub, bluehead

and flannelmouth s ucker, Colorado species of special concern; sculpin, and speckled

dace. Thes e native fis h species are declining range wide due to a number of factors

including

STATE OF COLORADO

John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources Steven M.Yamashita, Acting Director, Colorado Parks and Wildlife

Parks and Wildlife Commission: Robert W. Bray • Chris Castilian •Jeanne Home

Bill Kane,Vice-Chair • Gaspar Perricone • James Pribyl • John Singletary, Chair

Mari< Smith, Secretary • James Vigil • Dean Wingfield • Michelle Zimmerman Ex Officio Members: Mike King and John Salazar

degradation of habitat, reduced water quality and quantity. Any reduction in the

capability of forest resources to s upport naturally reproducing populations may have

severe consequences for the listing s tatus of thes e species.

Water Quality Concerns

Sanitation

All equipment used in the project should be disinfected per CPW protocol prior to and

after use of equipment in drainage. Decontamination protocol for chytrid should be

followed regardless of whether the equipment had been 'pre-disposed': Contractors

should always assume that the fungus is present and disinfect according. Rs -0-W in

areas that are known to be contaminated s hould be implemented last.

Erosion control and sedimentation

Erosion and sedimentation generated from the project activities have the potential to

affect fisheries . CPW recommends using the best avai lable method of erosion control

(applicable to site conditions) to ensure that runoff and sedimentat ion into creeks and

s treams is con t rolled.

Engineering and design standards

Use proper design standards for low water crossings. Culvert or bridge installations

should be constructed during dry periods to minimize erosion and sedimentation. These

structures should also not limit fish or river otter passage when they are installed.

Culverts or crossings should be constructed under heavily used roads to provide

migration corridors for use by amphibians and reptiles .

VEGETATIO CONSIDERATIONS

Integrated vegetation management plan

A project-wide noxious weed and invasive species inventory should be included in the

project planning; identification mapping and action plans should be developed and

integrated in to a comprehensive plan prior to any activity. Annual monitoring and

follow-up activities should be part of the planning and implementation for this project.

The introduction of or spreading of non-native, undes irable vegetation and noxious

weeds is a challenge to control in large-scale activities such as this vegetation

management project. Large scale projects create conditions favorable for the introduction

and s pread of weeds. Reducing the impact of weeds is a vigilant, and long-term

multiple s easons effort. Weed management activities should be monitored along with

reclamation success on at least an annual basis.

Reclamation

CPW encourages reclamation and subsequent monitoring be designed and i m plemented

to ensure superior results for areas of disturbance .

WILDLIFE HABITATS

CPW believe it is necessary to conduct pre-treatment biological surveys and clearance

for each area scheduled for treatment; ensure that s urveys are current. The timing of

implementing forest treatment activities should be based on the wildlife that is present at

the treatment location and its sensitivity and life stage needs ; CPW is particularly

interested in big game, aquatic species, raptors, migratory song birds and non-game

species.

CPW recommends that the Forest Service use best management practices (BMPs), to

minimize project impacts to species/habitat during critical life stages or seasons, for

example elk calving, mu le deer and elk winter range, spawning, or nesting periods.

CPW believes that select treatment methods s uch as controlled burns and hand

thinning are appropriate in sensitive or protected areas. Treatment areas should be

prioritized based on the importance and contribution to an overall healthy forest and

wildlife habitat even if the area falls within a protected area.

COLORADO SPECIES OF SPECIAL CONCERN

Project maintenance activities should avoid or minimize habitat impact and conserve

plants and animals that are s pecies of special concern. The actions of this project should

not degrade or des troy habitat that would lead to the overall decline of the species but

rather improve conditions so that the species can eventually be removed from the state

threatened or endangered status lists. Species and or habitats identified are boreal toad,

northern leopard frog, Gunnison's and white-tailed prairie dog, river otter and several

species of bat are known to use aspen and coniferous forest.

RECREATION CONSIDERATIONS

CPW and the Forest Service should work closely to coordinate road/travel designations,

opening s/closure. and seasonal use. CPW believes that a clear description of how roads

will be managed du ring active treatment periods and post treatment activities will benefit

recreation use and support for forest activities.

Big Game Hunting Seasons

Big game hunting season begins in late August (archery season) and continues until the

middle of November (rifle season); rural county roads and FS roads may see an increase in

traffic due to hunters being in the field. Forest Service staff and contractors should strive

to s c hedule a minimal amount of activities for peak hunting weekends during this time of

the year to avoid potential user conflict and accidents and provide hunters with a positive

experience. Where activities must occur in hunting season CPW encourages Forest Service

s taff and contractors to wear blaze orange or other brightly colored safety vest.

CPW RESEARCH

CPW staff is conducti ng r e s e arch regarding the impacts of beetle kill on mammals and

songbird communities in the state. Mammal studies will focus on snowshoe hare and red

squirrels as they are the primary prey species for lynx. CPW will be using cameras as the

primary sampling mechanism for mammals, which will capture many species, including

furbearers and other game species . Avian sampling will occur via point counts and the

analyses will be tied to the suite of s pecies that are amenable to that type of sampling.

CPW is planning to sample during 2 summer seasons, beginning May/June 201 3. CPW

intends to sample statewide, including a reas i mpacted by both pine beetle and spruce

beetle, so CPW staff will be working in all 4 regions. CPW would like to make the Forest

Service aware of these studies.

CPW respectfully offer these recommendations and comments in support of the Forest

Service's desire to develop a SBEADMR project document that will provide policy

protection of wildlife populations, habitat resources and vegetation communities within

the Grand Mesa, Uncompahgre, and Gunnison Forest boundaries. We value the

opportunity and ability to work together with the Forest Service on this important project.

If you have any questions or would like clarification on any comments in this letter please

contact Michael Warren at 970-255-6180.

Sincerely,

Ron D. Velarde, NW Regional Manager

cc. Steve Yamashita, Acting Director, Colorado Park & Wildlife

Chad Bishop, Assistant Director for Wildlife and Natural Resources

Patt Dorsey, SW Regional Manager

Dean Riggs, NW Assistant Regional Manager

Brad Petch, NW Senior Terrestrial Biologist

Sherm Hebein, NW Region Senior Aquatic Biologist

JT. Romatzke, Area Wildlife Manager

file

Page 1 of 4

No Surface Occupancy Timing Limitation Controlled Surface UseStipulation Stipulation Stipulation

Wildlife Habitat Species Types (area or buffer distance)

Roost Sites Within 0.25 Miles of Roost Site N/A

Bighorn Sheep (TL for human activities in these habitats including over flights)

Production Areas Entire Mapped Production Area April 15-June 30 (Rocky Mountain) February 1-May 1 (Desert) N/A

Winter Range Entire Mapped Winter Range Area November 1-April 15 N/A

Black Footed Ferret

Release Areas N/A Entire Area March 1-July 15 N/A

Columbian Sharp-tailed Grouse

Leks Within 0.4 Miles of Lek Sites N/A N/A

Winter habitat N/A Restrict development between Dec 1- March 15 Limit noise not to exceed 49 dB measured 30 ft. from source.

Production Areas (Breeding and Nesting habitat

N/A Within 1.25 Miles of Lek Sites March 15-July 30 Surface Density Limitation of one pad per section; Relocate compressors > 1.25 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Cutthroat Trout

Designated Cutthroat Habitat 300-Feet from OHWM SEE Aquatic Species stip N/A

Designated Cutthroat Habitat Watershed

N/A N/A Surface Density Limitation of one pad per section

Mule Deer

Crucial Winter Ranges (Severe Winter Range and Winter Concentration Areas)

N/A December 1-April 15 Surface Density Limitation of one pad per section or consider off site mitigation

Elk

Crucial Winter Ranges (Severe Winter Range and Winter Concentration Areas)

N/A December 1-April 15 Surface Density Limitation of one pad per section or consider off site mitigation actions

Production Areas N/A May 15-June 30 Surface Density Limitation of one pad per section or consider off site mitigation actions

CDOW Recommended Stipulations for Oil and Gas Within the State of Colorado

A bat inventory may be required prior to approval of operations within historic mining complexes. These are areas where bats are suspected or the habitat is deemed suitable but no bats have been documented. The inventory data will be used to apply conservation measures to reduce the impacts of surface disturbance on bat habitat

(time period - may be greater than 60 days) (potential facility relocate or other operational constraint)Bats (Brazilian Free-tailed, Townsend's Big-eared, Fringed Myotis)

Page 2 of 4

Gunnison/Greater Sage-grouse

Leks 1 Within 0.6 Miles of Lek Sites N/A N/A

Core Areas (Occupied Habitat = Core Area for Gunnison sage-grouse)

No Lease N/A Surface Density Limitation of one pad per section; Relocate compressors > 4 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Winter Range N/A December 1-March 15 Surface Density Limitation of one pad per section; Relocate compressors > 4 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Production Areas (Breeding and Nesting habitat

N/A Within 4 Miles of Lek Sites March 1-June 30 Surface Density Limitation of one pad per section; Relocate compressors > 4 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Greater Prairie Chicken

Leks Within 0.6 Miles of Lek Sites N/A N/A

Production Areas (Breeding and Nesting habitat

N/A Within 2.2 miles of Lek sites March 1-June 30 Surface Density Limitation of one pad per section; Limit noise not to exceed 49 dB measured 30 ft. from source.

Kit Fox

Den Sites N/A Within 0.25 mile of den sites February 1-May 1 Pre-construction survey for den sites may be required

Least Tern

Production Areas (Breeding and Nesting habitat)

Within 300 Feet OHWM 0.5 Miles-No Human Encroachment-April 1-July 31 N/A

Lesser Prairie Chicken

Leks 2 Within 0.6 Miles of Lek Sites N/A N/A

Core Areas No Lease N/A Surface Density Limitation of one pad per section; Relocate compressors > 2.2 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Production Areas (Breeding and Nesting Habitat)

Within 2.2 Miles of Lek Sites March 15-June15 Surface Density Limitation of one pad per section; Relocate compressors > 2.2 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Lynx

Consult with DOW regarding Lynx use of the development area

Mountain Plover Active Nest Site Within 300 Feet of Active Nest N/A Pre-construction survey for nest sites may be required

Piping Plover Production Areas (Breeding and Nesting Habitat)

Within 300 Feet OHWM Within 0.5-No Human Encroachment-April 1-July 31 N/A

Page 3 of 4

Plains Sharp-Tailed Grouse

Leks Within 0.4 Miles of Lek Sites N/A N/A

Core Areas No Lease N/A Surface Density Limitation of one pad per section; Relocate compressors > 1.25 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Production Areas (Breeding and Nesting Habitat)

N/A Within 1.25 Miles of Lek Sites-March 1- June 30 Surface Density Limitation of one pad per section; Relocate compressors > 1.25 miles from lek; Limit noise not to exceed 49 dB measured 30 ft. from source.

Prairie Dogs (White-tailed/Gunnison's)

Colonies N/A March 1-June 15 Pre-construction survey for active colonies may be required; avoid direct disturbance to active colonies when possible

Preble's and New Mexico Meadow Jumping Mouse

Known and Potential Occupied Habitat

Within 300 ft. of stream centerline N/A N/A

Pronghorn Antelope

Winter Concentration Areas N/A January 1-March 31 N/A

Bald Eagle

Active Nest Site 3 Within 0.25 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles- No Human Encroachment October 15-July 31

Active Winter Night Roost Sites 4 Within 0.25 Miles of Roost Site N/A Pre-construction roost surveys may be required

Active Winter Night Roost Sites N/A 0.5 Miles- No Human Encroachment November 15 - March 15Ferruginous Hawk

Active Nest Site 3 Within 0.5 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles- No Human Encroachment February 1-July 15

Golden Eagle

Active Nest Site 3 Within 0.25 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles- No Human Encroachment December 15-July 15

Mexican Spotted Owl

Protected Activity Centers (PAC) Entire PAC N/A Pre-construction nest surveys may be required

Protected Activity Centers (PAC) N/A Adjacent PAC Areas- No Human Encroachment March 1-August 31

Northern Goshawk

Active Nest Site 3 Within 0.5 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles- No Human Encroachment March 1-September 15

Osprey

Active Nest Site 3 Within 0.25 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.25 Miles- No Human Encroachment April 1-August 31

Peregrine Falcon

Active Nest Site 3 Within 0.5 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles- No Human Encroachment March 15-July 31

Page 4 of 4

Prairie Falcon

Active Nest Site 3 Within 0.5 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.5 Miles-No Human Encroachment March 15-July 15

Swainson's Hawk

Active Nest Site 3 Within 0.25 Miles of Nest Site N/A Pre-construction nest surveys may be required

Active Nest Site N/A 0.25 Miles- No Human Encroachment April 1-July 15

Other Raptors Not Listed Above

Nesting Habitat N/A No Human Encroachment January 1-July 15 Pre-construction nest surveys may be required

Roost Sites N/A No Human Encroachment November 15-April 1

Burrowing Owl

Active Nest Site N/A 300 Foot March 1-August 15 N/A

River Otter

Occupied Habitat N/A N/A Minimize disturbance of riparian vegetation and road development within 300 ft. of occupied habitat

Southwest Willow Flycatcher

Active Nest Site Within 300 Feet of Nest Site N/A Pre-construction nest surveys may be required

Suitable habitat (USFWS minimum patch size definition)

Restrict activities between May 15-Aug 1 Pre-construction nest surveys may be required

Swift FoxDen Sites N/A 0.25 Mile March 15-June 15 Pre-construction survey for den sites may be required

Northern Leopard Frog

Breeding Sites Within 0.25 Miles of Breeding Site N/A N/A

Western Boreal Toad

Breeding Sites Within 0.5 Miles of Breeding Site N/A N/A

Aquatic Species

Gold Medal Water 300 Feet from OHWM N/A N/A

Rainbow Trout N/A March 1-June 15 N/A

Brown Trout N/A October 1-May 1 N/A

Brook Trout N/A August 15-May 1 N/A

Cutthroat Trout N/A June 1-September 1 N/A

Bluehead Sucker N/A May 1-July 15 N/A

Flannelmouth Sucker N/A April 1-July 1 N/A

Roundtail Chub N/A May 15-July 15 N/A1 Greater and Gunnison sage-grouse lek = any lek active within last 10 years (core area); any lek active within last 5 years (outside core area)2 Lesser prairie chicken lek = any lek active within last 3 years

4 Active Bald Eagle Winter Night Roost = Areas where bald eagles gather and perch overnight, and sometimes during the day in the event of inclement weather.

3 Active Nest Site = any nest that is frequented or occupied by a raptor during the breeding season, or which has been frequented or occupied in any of the five previous breeding seasons

A ~ COLORADO~Z Parks and Wildlife

Department of Natural Resources

Southwest Region Office415 Turner DriveDurango, Co 81303

Mr. Scott Armentrout, Forest Supervisor 28 July 2015Grand Mesa Uncompahgre and Gunnison National Forests2250 Highway 50Delta, CO 81416

RE: COLoRADO PARKS AND WILDLIFE COMMENTS FOR THE DRAFT GRAND MESA, UNc0MPAHGRE, ANDGUNNIS0N NATIONAL FOREST ENVIRONMENTAL IMPACT STATEMENT (DEIS): SPRUCE BEETLE EPIDEMIC ANDASPEN DECLINE MANAGEMENT RESPONSE (SBEADMR)

Dear Mr. Armentrout:

Colorado Parks and Wildlife appreciates the opportunity to review the DEIS for the SpruceBeetle Epidemic and Aspen Decline Management Response. CPW provided scoping commentsand recommendations in September of 2013 and was pleased to see some of ourrecommendations incorporated into the DEIS. The following comments are submitted fromCPW Southwest Region. For reference the Southwest Region encompasses all of theUncompahgre National Forest (NF), all of the Gunnison NF except for a small portion nearRagged Mountain, and the portion of the Grand Mesa NF south of the Mesa-Delta County Lineto the Gunnison NE boundary (Figure 1.)

PROJECT SUMMARY ft RECOMMENDATIONS:We understand that the Grand Mesa, Uncompahgre, and Gunnison National Forest’s (GMUG)SBEADMR project is a proposal to implement multiple vegetation management actions to treatspruce and aspen forests impacted by spruce beetle and Sudden Aspen Decline. The purposeof these treatments is to improve forest resiliency and recovery and to reduce the publicsafety threats created by hazard trees.

The project proposes to treat a total of 120,000 acres over an 8-12 year period: commerciallytreating 4,000-6,000 acres per year and mechanically treating and/or using prescribed fire totreat approximately 3,000-6,000 acres per year. We understand the rationale in not specifyingthe treatment areas in the DEIS. It is our understanding that the GMUG will develop detailedplans of the treatment areas after the EIS is final and project implementation planningbegins. CPW is very interested in providing the GMUG with our on-the-ground wildlifeexpertise to assist in treatment design and implementation.

Spruce/fir and aspen forests are some of the most widespread and productive habitat typesfor a wide variety of wildlife species in Colorado. The beetle epidemic has the potential tochange forest types at a landscape scale, with or without treatment. The ecological effects ofthis conversion are difficult to predict. Consequently, we anticipate that wildlife responsesfrom the spruce beetle epidemic will be complex, species specific, and Spatially andtemporally dynamic.

Bob D. Broscheid, Directcr, Cc1~ado Parks and Wildlife • Parks and Wildlife Commissicn: Robert W. Bray, Chair • Chris Castilian, Vice chairJeanne I-I~ne, Secretary . .lthn Howard, Jr. • Bill Kane • Dale Pizel • James Plibyt • James Vigil • Dean Wingfietd • Michelle Zimmerman • Alex Zipp

CPW offers the following recommendations on the Draft EI5/SBEADMR with the intent ofassisting the GMUG in its preparation of a compelling final ElS. Comments and supportinginformation follow these recommendations.

1. For the “Three Species,” i.e., flannelmouth sucker, bluehead sucker, and roundtailchub, CPW recommends: conducting an inventory and analysis, identifying treatmentareas and mapped conservation waters within the project boundary and developingdesign criteria and features to protect native fish and their habitats;

2. Add and/or strengthen design features to avoid the spread of invasive species;3. For big game species, CPW recommends: designing specific projects to meet USFS

objectives and CPW’s mule deer strategy, coordinating timber harvest activities andor burns to avoid critical time periods for big game, incorporating timing Limitationsinto design features so they remain in pLace for Life of the project.

4. For Gunnison Sage Grouse, CPW recommends: conducting a Section 7 consuLtationwith the U.S. Fish and Wildlife Service (USFWS) within designated Critical Habitat,coordinating with the BLM as described in the final EIS Record of Decision, conductinga review of potential treatment areas within designated Critical Habitat to applytreatments to aspen stands.

5. For Canada lynx, CPW recommends: including design criteria to minimize understorydisturbance and including a project selection criterion to evaluate the understory andadvanced regeneration, and avoiding quality lynx/hare habitat.

6. Adopt a road planning and implementation strategy so that the project achieves anoverall no net increase of road miles within the project boundary and treatmentareas.

AQUATIC WILDLIFE SPECIES: NATIVE NON-SALM0NID FISH HABITATAn inventory and analysis of the potential impacts to “the Three Species,” will add greatvalue to the integrity of the final EIS.1 Streams such as Cunningham Creek, Terror Creek andHubbard Creek Middle Fork in Delta County are examples of habitats fall within the proposedtreatment area and may be affected.

AQUATIC WILDLIFE SPECIES: INVASIVE SPECIESCPW recommends that the Forest Service add and/or strengthen design features that addressequipment sanitation to avoid the spread of Aquatic Nuisance Species (ANS), noxious weedsand other invasive species. Decontamination protocol for chytrid fungus should occurregardless of whether the equipment had been “pre-disposed.” Forest Service contractorsshould always assume that the fungus is present and disinfect accordingly. Areas that areknown to be Contaminated with chytrid fungus should be treated last.

TERRESTRIAL WILDLIFE SPECIES: BIG GAMECPW supports large aspen treatment projects (>40 acres) when they avoid crucial sensitiveperiods for big game. We recommend that the Forest Service incorporate specific timelinesinto design features so that the timing of treatment activities and wildlife protections remainconsistent over the life of the project. Attached is a document titled Colorado Recommended

1 These three native fish are USFS “Sensitive Species.” The Upper Colorado River Basin States (Colorado, Utah and

Arizona) have adopted a Rangewide Conservation Agreement for these species and CoLorado has designated theroundtaiL chub as a State Species of SpeciaL Concern.

2 Page

Stipulations for Oil and Gas within the State of Colorado (Attachment 1). While CPWdeveLoped this document to reduce impacts from oil and gas operations on wildLife, many ofthe timing and distance buffer recommendations are applicable in developing designguidelines to protect wildlife in other Land use/management plans, including the Final EIS.

Mule deer are mentioned infrequently in this planning document. This iconic western big-game animal has been declining throughout the West, in numbers and distribution, due to avariety of causes. Colorado’s estimated population in 1983 was about 625,000. Today,Colorado’s population is estimated at 391 ,000. Due in part to the growing concern about muledeer populations across the West, Colorado is implementing a “MuLe Deer Strategy.” We thinkthat the SBEADMR project is an ideal opportunity to coordinate treatments that achieve forestobjectives and CPW’s objectives outlined in our deer strategy.

CPW supports the Forest Service’s range of tools proposed to implement forest treatments.Our Mule Deer Strategy (2014) recommends many of the same treatment tools e.g., hydroaxe, roller-chop, prescribed fire, etc. to manage habitat for deer. CPW requests that theForest Service identify opportunities to add the foLlowing actions in the planning, designfeatures, and implementation of site specific project activities:

1) Pursue separate habitat treatments for deer and elk on the same Landscapes tominimize overlap and lessen forage competition;

2) Work closely with CPW staff to create and share a habitat treatment and monitoringdatabase for this project;

3) Work closely with CPW staff to monitor effectiveness of habitat management to informfuture decisions.

Big game hunting season begins in Late August (archery season) and continues until the middleof November (rifle season); rural county roads and FS roads may see an increase in traffic dueto hunters being in the fieLd. We recommend that Forest Service incorporate a design featureto help schedule a minimal amount of activities for peak hunting weekends during this time ofthe year to avoid potential user conflicts and provide hunters with a positive experience.

TERRESTRIAL WILDLIFE SPECIES: GUNNIS0N SAGE-GROUSEIn November of 2014, the United States Fish and Wildlife Service (USFWS) determined that theGunnison sage-grouse (GuSG) warranted protection as a threatened species under the federalEndangered Species Act (16 U.S.C. 1531-1534). Management activities within designatedCriticaL Habitat require a Section 7 consultation with the U.S. Fish and Wildlife Service(USFWS).

GuSG require a variety of habitats, including Large expanses of sagebrush with a diversity ofgrasses and forbs (fall and winter) and heaLthy wetland and riparian areas including aspenstands (at approximately 8500-9500 feet in elevation) for summer brood rearing. The ForestService Draft ElS states on page 298 that: “ALthough the proposed treatment activities do notinvolve suitable habitat for this species, Gunnison sage-grouse could potentially be affectedbecause transportation routes to access treatment areas and hauL material may crossoccupied habitat consisting of National Forest, Bureau of Land Management and privatelands.” We concur that hauLing could negatively impact Gunnison sage-grouse. We also see anopportunity to enhance GuSG habitat in some aspen treatment areas.

31 Page

The Colorado State Office of the Bureau of Land Management (BLM) is preparing aprogrammatic EIS for GuSG. The USFS and CPW are Cooperating Agency partners in thedevelopment of that ElS. We recommend the Forest Service work closely with the BLM toaddress Gunnison sage-grouse protections described in the final ElS Record of Decision.

CPW reviewed the overlap between potential project locations in the SBEADMR DEIS (GMUG)aspen and spruce map layers and the USFWS’ designated Critical Habitat and found numerouslocations where treatment areas lie within designated Critical Habitat. We recommendconducting a more extensive review of potential treatment areas within designated CriticalHabitat to apply treatments to aspen stands. CPW has identified the following potentialtreatment areas within the Southwest Region that lie within Critical Habitat for your reviewand consideration:

Montrose County: T45N, R11W, 516, New Mexico Meridian; T46N, R11W, 534, New MexicoMeridian; T49N, RoW, 514, 15, 16, 21, 22, 23, 26, 27, New Mexico Meridian

Gunnison County:T15S, R87W, 525, 26, 36, 6PM; T49N, R4W, 55, 6, 7, 8, New Mexico Meridian; T49N, R5.5W,512, 14, 23, New Mexico Meridian; T49N, R6W, S13, 24, 25, New Mexico Meridian; T5ON, R4W,531, 32, New Mexico Meridian; T51N, R2W, 510, 11, 14, New Mexico Meridian

Saguache County:T45N, R1E, 59, 10, 15, New Mexico Meridian; T45N, R2E, S25, New Mexico Meridian; T46N,R3E, 55, 16, 20, 21, 28, New Mexico Meridian; T47N, R1E, 510, 11, 12, 13, 14, 15, 22, 23, 24,New Mexico Meridian; T47N, R3E, 531, 32, New Mexico Meridian

Most of these lower elevation aspen stands are smaller patches, and treatments may besusceptible to over browse by domestic cattle and wild ungulates. In order to achievetreatment goals and desired outcomes, treatments in these stands need to be carefully timedand on a sufficient landscape scale. Please refer to, the GuSG Rangewide Conservation Plan(RCP 2005) (http: //cpw.state.co.us/learn/Pages/GunnisonsagegrouseConservationplan.aspx)and the USFWS to develop appropriate design features to ensure that impacts on Gunnisonsage-grouse from the proposed project are avoided, minimized, and mitigated.

TERRESTRIAL WILDLIFE SPECIES: LYNXCPW reintroduced lynx in Colorado from 1999-2006 and actively monitored lynx through 2010.Subsequently we have a significant amount of data on lynx locations and den sites. In thefall/winter of 2014/15 CPW initiated a long term lynx occupancy monitoring program in theSan Juan Mountains, and collaborated with the Rio Grande NF on a lynx project designed toevaluate the impacts from spruce beetle kill on lynx and snowshoe hares

Snowshoe hares comprise a major portion of the lynx diet. Hare populations in Colorado relyheavily on the understory structure and advanced regeneration of the forest. In areas whereunderstory structure exists or has been enhanced by over-story mortality hare populationshave benefited. Results from CPW and USFS monitoring efforts indicate that lynx are stillpresent in nearly all of the areas they inhabited prior to the spruce beetle outbreak on theRio Grande NF (roughly 4-6 years ago depending on location). In 2015 two GPS-collared female

41 Page

Lynx produced kittens within beetLe~kilLed forest patches. Thus, we believe that areas Lackinga Living overstory, but with a sufficient understory are continuing to function as Lynx habitat.

The ElS indicates that when timber is saLvaged, some portion of the understory is disturbed ordamaged. We recommend including design criteria to minimize understory disturbance thatmay degrade Lynx and hare habitat quality. Design criteria may include: increasing distancebetween skid trails, using machinery to pLuck and stack Logs, and requiring winter saLvage,etc. in areas with advanced understory regeneration.

In addition, the EIS identifies several types of forest stands and provides treatmentprescriptions for each type. We agree that many of the prescriptions wiLL benefit hares andLynx e.g., single storied stands without much understory. However, other stands e.g., muLti-or single story with >35% Dense Horizontal Cover could not be improved by and would Likelybe degraded by salvage activity to some degree for hares and Lynx.

We recommend that the USFS include a project selection criterion that evaluates theunderstory and advanced regeneration, and avoids areas that are functioning as qualityhabitat for lynx/hare. Of particular importance are those areas where current or historic dataindicate that lynx are/were present. We believe that this approach will aid the USFS in thedesign and identification of specific treatment areas that will be most beneficial to lynx andminimize potential disturbance lynx from treatment activities.

OTHER C0MMENTs/REc0IAMENDATI0N5: ROADS AND REcUMATI0NThe Forest Service made deliberate and thoughtful decisions with regard to 2010 TravelManagement Plan throughout the GMUG. CPW is very supportive of those decisions with thelong-term goals of preserving blocks of unfragmented wildlife habitat, and holding big game,particularly elk, on public lands where they are available for harvest by public land hunters.Road density and utilization, vegetation management and recreation management mayimpact effective use of habitat by mule deer, elk, and other species. Maintaining or reducingroad density consistent with the 2010 Travel Management Plan will provide more usablehabitat within the treatment area for wildlife.

Our review of the DEIS did not indicate if the designed roads and temporary roads would beclosed to the public during active treatment and post treatment restoration and monitoringperiods. If left open these routes may impact habitat effectiveness for wildlife.

CPW supports road decommissioning after treatments are completed. If implemented fully asproposed (proposed action), the Forest Service will end up with a net increase of 12 miles ofnew roads. CPW recommends that the Forest Service adopt a road planning andimplementation strategy so that the project achieves an overall no net increase of road mileswithin the project boundary and treatment areas. Given the limited amount of new roadsbeing proposed, it seems reasonable that the Forest Service could reach that goal.

OTHER COMMENTs/REcoMMENDATIoNS:Recent research conducted by CPW on the wildlife response to habitat treatments hashighlighted the need to evaluate and consider domestic grazing system influences onvegetation treatment response. We suggest that the GMUG incorporate and evaluate grazingsystem management in the analysis area.

51 Page

Given the economics associated with trucking saLvaged Logs, CPW understands that thetreatment areas will be focused in areas closest to existing miLls. We encourage the USFS toselect project Locations that will have the greatest benefit on regeneration of the forest,pubLic Land users, and wiLdLife throughout the opportunity area in addition to providingeconomic efficiency.

CooPERATIoNCPW appreciates the cooperative nature and collaborative approach to project managementthat is built into this ElS, specificaLly at the project impLementation stage. CPW staff Looksforward to participating in pLanning, on site visits and when preparing design features. CPWbeLieves cLose cooperation leads to projects that benefit wiLdLife and produce effective foresttreatments.

Thank you for the opportunity to review the DEIS: SBEADMR. We respectfuLLy offer thesecomments and recommendations in support of the Forest Service’s desire to develop adocument that will protect wiLdlife and its habitat within the GMUG National Forest. We vaLuethe opportunity and ability to work with you on this important project. If you have anyquestions or need cLarification on this letter pLease contact Southwest Regional Land UseCoordinator, Brian Magee at 970-375-6707.

Sincerely,

Patricia D. Dorsey,Southwest Region Manager

xc: Ron veLarde, NW Regional Manager, Scott Wait, Senior TerrestriaL Biologist, John ALves, Senior AquaticBiologist, Jon HoIst, Energy Liaison, Renzo DelpiccoLo, Area wildlife Manager Montrose, J. Wenum Area WildlifeManager, Brian Magee, Land Use coordinator, Jake Ivan, Mammals Researcher, SWR File

Attachments: Figure 1. Map; Attachment i. colorado Recommended Stipulations for Oil and Gas within the State ofcolorado

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Figure 1.CPW Administrative Region Boundaries within the GMUG

DELTA COUNTY, COLORADO BOARD OF COUNTY COMMISSIONERS

COUNTY COURTHOUSE • 501 PALMER STREET • SUITE 227 • DELTA • COLORADO • 81416-1796

PHONE: (970) 874-2100 FAX: (970) 874-2114

www.deltacounty.com

Dist. 1: C. Douglas Atchley - Dist. 2: C. Bruce Hovde - Dist. 3: J. Mark Roeber

July 31, 2015 Scott Armentrout Forest Supervisor Grand Mesa, Uncompahgre, Gunnison National Forest 2250 Highway 50 Delta, CO 81416 SUBMITTED ELECTRONICALLY and VIA CERTIFIED MAIL RE: DRAFT EIS – SBEADMR Project Dear Scott,

Delta County greatly appreciates the tremendous amount of work you and your staff have put into the SBEADMR project. Delta County has been at the table and worked in partnership with US Forest Service and all of the stakeholders from the onset of the project. We will continue to work through the entire NEPA process, appeal period and adaptive management phases. We commend the GMUG Forest for making this a template of how to treat large landscapes and address real safety concerns and continuing to provide for multiple use industries on our forestlands. The following comments are specific to the Draft EIS (DEIS) for the SBEADMR Project. The DEIS proposes a proactive 8-12 year approach to move the GMUG to a healthier natural state, enabling the use of dead timber while the timber still has a market value and improving the safety of areas surrounding roads, campgrounds and trails. We thank the GMUG and other Forest Service staff for the tremendous amount of work to provide significant public participation, increase the level of understanding and for keeping science at the basis for decision making. We encourage the adaptive management phase of the project to keep the science at the core of the decision making and not the “published work of the week.” In addition, we encourage the GMUG to continually stress the participatory model in the action part of the adaptive management.

We commend the Forest Service for maintaining a relatively consistent acreage total for the treatment in the alternatives. Delta County requests that these acreage targets be maintained throughout the entire NEPA and implementation process. We support Alternative 2, the preferred alternative with the caveat that additional salvage treatments from Alternative 4 are added per resource needs, and that our comments are considered and incorporated into the selected alternative. Specifically, Delta County would ask that the 21,000 ccf of salvage timber from Alternative 4, the Salvage Alternative, with the resiliency and salvage timber already included in Alternative 2, the Preferred Alternative. This would add additional safety precautions in several of the previously identified WUI areas and objectives and add flexibility to respond to changing conditions on the ground. Data previously obtained for historical timber projects indicate that adding additional salvage timber to Alternative 2 would provide 332 jobs to those already detailed in the preferred alternative. Delta County has lost 500 coal mine jobs in the last two years and this job boost would help bridge our current deficit in good paying jobs for families in the area. The rate of spruce beetle mortality and standing dead will clearly outpace this project and therefore the additional evidence that adding additional salvage to the preferred alternative is the right science on the ground for the safety of our county residents and visiting tourists. The priority for the first five years should be to remove the trees that are marketable and not delay sales in the name of process. Delta County cannot stress enough our support of additional treatment acres as this also assists the GMUG in ensuring the safety of firefighters as these forests will burn and the professional should not be put at risk because of aesthetics. Therefore we request revisions to Hazard Tree Removal as outline on page 45. Revised language should specify that mechanical and non-mechanical fuels management activities shall be conducted within a half mile buffer of roads open to the public and other identified infrastructure. This is necessary for firefighter and public safety. Resiliency is often touted as a reason to tackle forest health issues as it should for long term sustainability. The resiliency language should be highlighted in the EIS given the emphasis and science that it received in the SBEADMR Science symposium and numerous conversations. It is buried in the DEIS and should be highlighted. Visually sensitive areas are also ever changing and we encourage the GMUG to not automatically remove them from mechanical treatment consideration. This is especially true for aspen areas where treated areas have been proven to be more resilient to aspen decline. Visually sensitive areas should be considered during the adaptive management and monitoring process and not taken of the table from the onset. Forest management is a focused way of achieving age class diversity even in beetle infested environments and should clearly be a goal in the aspen response due to the importance of aspen habitat. Age diversity management is the long term solution to maintaining certain visually sensitive areas. Delta County would encourage that the socio-economic portion be further delineated to pull out the 10 counties within the GMUG. To rely on IMPLAN for 22 Counties does not accurately reflect the smaller operators and jobs. Socio economic goals for Delta County include:

to protect the existing jobs and the companies that provide them;

to help increase economically-sustainably capacity in service work;

Delta County believes that the preferred alternative with the additional salvage timber sales will provide sustainable jobs and industry for our areas while maintaining the aesthetic wilderness landscapes that are right out our back door. Delta County takes exception to the DEIS when it states that “County road maintenance could result in additional impact to individual such as crushing, or removal by road maintenance equipment.” (Page 219). Delta County works cooperatively with the GMUG on several roads, culvert projects and other special areas most notably the County Line Parking area for cross country skiers and recreationists. The work conducted by Delta County adheres to the same standards as the Forest Service road contractors and our Road and Bridge department is fully capable of performing high quality work. Delta County requests that this be removed from the DEIS. Delta County requests that a formalized stakeholder group be formed to continue the informed public involvement that addresses the economics, science and adaptive management phases of the SMEADMR project. The stakeholder group should reflect a balance of the multiple uses interests of the entire GMUG area and counties. The stakeholder process must truly be an active participatory going forward and we look forward to working with all stakeholders.

Sincerely, Delta Board of County Commissioners

___ J. Mark Roeber, Chairman C. Douglas Atchley, Vice Chairman C. Bruce Hovde, Commissioner

Ref: 8EPR-N

Scott Armentrout, Forest Supervisor

Grand Mesa, Uncompahgre, and

Gunnison National Forests

2250 Highway 50

Delta, Colorado 81416

Re: Draft Environmental Impact Statement for the Spruce Beetle Epidemic and Aspen Decline

Management Response Project; CEQ # 20150151

Dear Mr. Armentrout:

The U.S. Environmental Protection Agency Region 8 has reviewed the U.S. Department of Agriculture

Forest Service’s (USFS’s) Draft Environmental Impact Statement (EIS) for the Spruce Beetle Epidemic

and Aspen Decline Management Response Project (Project). The USFS Grand Mesa, Uncompahgre and

Gunnison (GMUG) National Forests propose to proactively and adaptively respond to declining forest

conditions that have resulted from large-scale insect and disease outbreaks by promoting recovery from

the insect outbreak, improving the resiliency of green stands to future disturbances, and providing for

human safety. Our review was conducted in accordance with the EPA’s responsibilities under section

102 of the National Environmental Policy Act (NEPA), and Section 309 of the Clean Air Act (CAA).

Project Background

The Project proposes to treat spruce and aspen forests impacted by the ongoing spruce beetle epidemic

and sudden aspen decline (SAD), as well as areas identified as high risk across the GMUG National

Forests that are located on the western slope of the Rockies and into the Colorado Plateau. Of the

3,161,900 acre range, the GMUG has experienced approximately 223,000 cumulative acres of spruce

beetle mortality and 229,000 acres of affected aspen over the past decade. The Project’s adaptive and

integrated approach will be applied at the landscape level to define opportunity areas available for

treatments, priorities for treatment, parameters and design features, operating protocols, monitoring and

activity tracking. The primary tools for reducing tree mortality, safety threats and fire hazard in stands

already experiencing beetle-induced mortality will be the removal of dead and dying trees. Forest

resiliency will be addressed under some alternatives in threatened stands by reducing stand densities.

Aspen stands may be identified as candidates for regeneration treatments. Management tools may

include one or more of the following: commercial harvest; non-commercial treatments (mechanical and

prescribed fire); recovery and resiliency treatments; hazard tree removal; and reforestation. Temporary

and/or designed road construction will likely be necessary.

Although landscapes of various extent are identified as opportunity areas and analyzed under the action

alternatives in the Draft EIS, the USFS is proposing treatments for a maximum of 120,000 acres under

all action alternatives over the approximate 8-12 year implementation period of the Project. In addition

to the No Action alternative, three action alternatives are identified. Alternative 2 (Proposed Action)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

1595 Wynkoop Street

Denver, CO 80202-1129

Phone 800-227-8917

www.epa.gov/region08

2

includes a total of 718,000 opportunity acres where commercial, non-commercial and mechanical and

prescribed fire treatments could be implemented. Commercial treatments on suitable timber production

areas would be largely limited to the identified 24 focus Lynx Analysis Units (LAU), while non-

commercial treatments would be primarily focused outside of suitable lynx habitat. Alternative 3 (Public

Safety Focus) limits the geographic extent of treatments exclusively to the wildland urban interface

(WUI) and outside the WUI, proximal to roads and additional human infrastructure, for a total of

426,000 opportunity acres. Alternative 4 (Spruce Salvage) limits spruce treatments to salvage only, and

aspen treatments would be the same as Alternative 2. The potential treatment area would be the same as

Alternative 2 (718,000 acres), except commercial mechanical treatments would also occur in areas

outside of the 24 identified focus LAUs, resulting in an additional 50,000 acres available for commercial

treatment opportunities compared to Alternative 2.

Comments and Recommendations

Our comments on the Draft EIS focus on whether there is sufficient information to determine impacts

when site-specific treatment locations are not identified at this point in the NEPA process. Where

impacts cannot be predicted, it is imperative that safeguards are in place such as the design features, best

management practices (BMPs) and adaptive management frameworks. In some instances we understand

that projecting potential impacts may be difficult without site-specific information. However, there may

be information currently available that would be beneficial to include in the Final EIS to provide for a

more robust analysis. Our concerns and/or recommendations are primarily related to potential impacts to

aquatic resources, including fens, as well as the air resources analyses.

1) Aquatic Resources

The area includes aquatic resources having high Watershed Condition Class scores and hydrologically

dependent riparian areas and wetlands including fens. The EPA considers protection of aquatic resources

to be among the most important issues to be addressed in the NEPA analysis for vegetation management

activities. As outlined in the Draft EIS, most treatments contemplated under the action alternatives (e.g.,

tree removal, thinning, road construction) have the potential to adversely impact aquatic resources,

including surface and ground waters, wetlands, streams, riparian areas, and their supporting hydrology.

Watersheds: The GMUG reclassified Watershed Condition Class as part of a 2011 national effort. We

understand that the USFS bases watershed condition on a 12-indicator model that considers both aquatic

and terrestrial physical and biological indicators. The Draft EIS explains that a watershed is considered

to be functioning properly (Class 1) if the physical attributes are appropriate to maintain or improve

biological integrity (i.e., the watershed is functioning in a manner similar to natural Wildland

conditions). Class 2 and Class 3 watersheds have impaired function because some physical,

hydrological, or biological thresholds have been exceeded. According to the Draft EIS, the GMUG

includes 231 watersheds. There are 156 Class 1 (functioning properly) watersheds, 75 Class 2

(functioning at risk) watersheds, and no Class 3 (impaired function) watersheds in the area. Of the 156

Class 1 watersheds, 51 are borderline Class 1/Class 2. Additionally, 212 of the 231 watersheds in the

GMUG include state delineated Source Water Areas. These areas are managed for multiple use outputs

while providing protection of water quality to meet municipal water supply needs.

Recommendations

The Draft EIS states that it is unlikely that proposed treatments will result in a change in Watershed

Condition Class score. Surveys will identify areas of concern to be avoided, such as fens or wetlands,

and effects tracking will evaluate potential adverse or beneficial effects of the proposed treatment. If

3

treatment-specific surveys indicate that the treatment could move the watershed toward a more impaired

condition, the proposed treatment may be modified and monitoring will be conducted.

Appendix B includes project design features to assist with water quality and soil productivity objectives

to protect watershed resources. Appendix C includes the Pre-Treatment Checklist, with the first planning

step being identification of priority watersheds for treatment. We support the USFS’s intent to modify

treatment as needed to avoid increasing impairment of watershed conditions as outlined under the soil

and water surveys. However, the instructions lack additional detail for modification prescriptions. To the

extent practical, we recommend including information in the Final EIS detailing treatment option

approaches. We recommend the Final EIS more specifically identify potential project impacts and the

treatment options available to prevent further degradation and reach watershed health objectives if

project design features and BMPs fail, such as those outlined in Appendix B and Table 15. Additional

information could include an expanded list of adaptive management options to address situations when

monitoring does not indicate progress toward desired conditions as outlined in our scoping comments.

For example, it may be necessary to consider larger buffers than usual around wetlands, streams and

lakes during treatments.

Wetlands/Riparian Areas/Fens: There are approximately 128,019 acres of riparian areas including

floodplains within the GMUG, with 20,671 acres of riparian areas occurring within opportunity areas.

The USFS manages springs as a subset of wetlands due to their unique characteristics and importance to

groundwater dependent ecosystems. Of the approximately 508 springs within the GMUG, 235 are

within opportunity areas. Additionally there are approximately 8,071 acres of fen and associated

wetlands within the GMUG; the Draft EIS states that nearly all are within opportunity areas. As outlined

in the Draft EIS, fen communities are very sensitive to hydrologic alternations and restoration is

extremely challenging once function has been impaired. Due to the slow rate of accumulation of peat in

fens, these ecosystems are generally considered to be irreplaceable. In addition, there appears to be eight

sensitive plant species on the GMUG known to occur in fens.

The wetlands typically found in mountain environments represent highly valuable upper montane and

lower subalpine wetland ecosystems performing a variety of functions and values. The Executive Order

11990 – Protection of Wetlands (May 24, 1977) requires federal agencies to avoid to the extent

practicable, long- and short-term adverse impacts associated with the destruction or modification of

wetlands.

Fen wetlands provide important hydrological and water quality functions by improving water quality in

headwater streams and may support rare assemblages of aquatic invertebrates. They also provide critical

ecological functions such as providing base flows to streams during late summer and/or drought periods.

The U.S. Geological Survey has also determined that peat wetlands are especially efficient filters of

metals dissolved in groundwater and surface water. The capacity to filter metals contributes to improved

water quality by lowering dissolved metal content in streams (Owens, D.O., and Breit, G.N., 1995),

which is particularly relevant to the project area regarding the water quality standard (WQS)

exceedances related to metals concentrations discussed below.

Recommendations

The Draft EIS (p. 88) states that “There are at least 8,071 known fens within the GMUG and nearly all

are within opportunity areas.” However, Table 13 (p. 87) identifies 3,073 acres of the total 8,071 acres

are within opportunity areas. In addition, page 205 references a total of 11,034 acres of fens estimated

within the GMUG, with 81% rated in “high” condition. We recommend this information be checked for

consistency and clarified throughout the Draft EIS. Regardless, the acreage within this range is

4

substantial.

The EPA recognizes fen-type wetlands as ecologically critical in that they provide local and regional

biodiversity. The U.S. Fish and Wildlife Service (USFWS) designated fen wetlands a Resource

Category 1 with respect to the USFWS Peatland Mitigation Policy. The mitigation goal of USFWS

Resource Category 1 is no loss of habitat values and the Peatland Mitigation Policy places the protection

and avoidance of fen wetlands as a priority during CWA Section 404 reviews. Further underlying the

uniqueness and importance of fen wetlands in Colorado, the Corps revoked the use of Nationwide

Permits in fen wetlands to protect this unique wetland type. In the EPA’s view, these wetland

ecosystems are, for all practical purposes, non-renewable and irreplaceable. Therefore, in accordance

with the goal of no overall net loss of the nation’s remaining wetland base for the Section 404 regulatory

program, we strongly recommend that both direct and indirect impacts to these highly valued resources

be avoided.

Because of the irreplaceable nature and rarity of montane fen wetland ecosystems, compensation for

these wetland impacts is extremely difficult. The Draft EIS states that Forest Service policies and BMPs

nationally and regionally severely restrict any activities in wetlands (including fens) and limit activities

in the water influence zone (WIZ) around them, and as a result, activities associated with implementing

this project will avoid fens. Although there are established design criteria, including buffers around fens

and associated wetlands so that the use of mechanical equipment and proposed treatments are restricted

in WIZs to protect habitat and functions (Draft EIS p. 88, Table 14), this does not appear to necessarily

apply to roads. According to the Draft EIS, proposed roads would be located outside of fens and

wetlands, and to the extent feasible, WIZs (p. 98). WIZs include riparian areas, floodplains and

depressional recharge areas, and are some of the most ecologically diverse habitat types that provide

bank stability, sediment filtering, streamside shading and nutrient input into streams and lakes (Draft

EIS p. 88). We therefore recommend the Draft EIS clarify whether the placement of roads will be

subjected to the same buffer zones as mechanical equipment in relationship to the water resources listed

in Table 14, and advocate that roads also be located outside of WIZs to reduce adverse impacts to these

hydrology supporting aquatic ecosystems. Road cuts can potentially intercept groundwater that supports

fens. Finally, we support the USFS’s efforts to potentially move some existing roads located within the

WIZs or other sensitive areas, and employ improved erosion control measures to reduce impacts to

riparian areas and provide a beneficial effect to watersheds.

Water Quality: The Draft EIS briefly mentions that the State of Colorado identified segments in 21

streams totaling approximately 141 miles that do not meet water quality standards within the Forests’

boundaries, generally due to metals concentrations. The Draft EIS states that proposed treatment

activities are unlikely to affect the specific impairments in the identified waterbodies, and that design

features and BMPs will be used to minimize the potential to adversely impact other water quality

parameters, such as sediment, turbidity and temperature.

Recommendations

Although the Draft EIS references the project file to find a list of the impaired streams and their

beneficial uses, we recommend that these details be included in the Final EIS. Currently the limited

information contained in the Draft EIS is not sufficient to understand baseline conditions, including the

specific delineation of mine-induced impaired waters versus those waters with impaired water quality

parameters that are more at risk for project impacts (e.g., temperature, dissolved oxygen, pH, sediment,

turbidity). We recommend that the Final EIS include Clean Water Act (CWA) Section 303(d) listed

waterbodies that are within the GMUG, including any occurring within opportunity areas, and more

specifically identify potential project impacts along with specific design features and BMPs that will be

5

used to avoid or minimize these impacts. Proposed road locations, especially stream crossings, and

treatment activities could exacerbate impaired conditions.

We recommend that the Final EIS analyze potential impacts to surface waters related to erosion and

sedimentation from land disturbance and stream crossings, as well as potential impacts associated with

project treatment activities. We also recommend that the USFS (a) analyze potential impacts to impaired

water bodies within and/or downstream of the planning area (including water bodies listed on the most

recent EPA-approved CWA § 303(d) list), and (b) coordinate with the Colorado Department of Public

Health and Environment (CDPHE) if there are identified potential impacts to impaired water bodies (in

order to avoid causing or contributing to the exceedance of water quality standards). Where a Total

Maximum Daily Load (TMDL) exists for impaired waters in the area of potential impacts, pollutant

loads should comply with the TMDL allocations for point and nonpoint sources. Where new loads or

changes in the relationships between point and nonpoint source loads are created, we recommend that

the USFS work with CDPHE to revise TMDL documents and develop new allocation scenarios that

ensure attainment of water quality standards. Where TMDL analyses for impaired water bodies within

or downstream of the planning area still need to be developed, we recommend that proposed activities in

the drainages of CWA impaired or threatened water bodies be either carefully limited to prevent any

worsening of the impairment or avoided where such impacts cannot be prevented. We recommend that

mitigation or restoration activities be considered in the Final EIS to reduce existing sources of pollution,

and to offset or compensate for pollutants generated.

In much the same way as Figure 15 illustrates watershed condition classes and fen/wetland locations in

the Draft EIS, we recommend that the Final EIS include a map identifying the locations of the impaired

streams in relationship to the project area. This additional information will enable stakeholders to more

fully understand the potential for impacts from this landscape approach project.

In addition, for streams with a coldwater designation, we recommend consideration of specific measures

to reduce impacts to stream temperature. Such measures may include limiting removal of trees in areas

where no other trees or shrubs provide stream shading along with tree planting or cattle exclosures

designed to restore vegetative shade to impacted streams.

Design Features, BMPs, and Adaptive Implementation and Monitoring: We support the efforts of the

USFS to avoid and minimize impacts through design features and BMPs. We also support the adaptive

implementation framework developed to define treatment locations and design, define monitoring

questions, require annual monitoring review and evaluation of treatment effects, and adjust management

towards desired conditions throughout the project implementation period. We recommend expanding

protective measures to include the following:

Develop design criteria and/or mitigation measures to protect reservoirs, particularly if

treatments could occur adjacent to these important resources. Such measures may include

operational requirements for treatments implemented directly adjacent to reservoirs and/or

monitoring impacts to reservoir water quality from project activities.

Specify steps to protect range improvements (fencing, exclosures, etc.) that protect water quality

and habitat.

2) Air Resources Analyses

We appreciate that many of our scoping recommendations related to air resources were addressed in the

Draft EIS. Please see our remaining comments and recommendations below.

6

Air Quality Modeling: The Draft EIS references the U.S. EPA’s Motor Vehicle Emissions Simulator as

MOVES2014b that was used for generating equipment emissions factors in the analysis. Please note that

there was an earlier version of this model called MOVES2010b. However, the most recent version is

MOVES2014. Please clarify in the Final EIS which version was used for the analysis. Although

MOVES2010b can currently be utilized for NEPA purposes since it’s within the 2-year grace period of

the release date, the latest version of MOVES2014 is recommended for new projects coming online as it

includes updated information helpful for analysis.

Greenhouse Gas (GHG) Emissions and Climate Change: We appreciate the discussion of climate change

and the inclusion of GHG emissions inventories in the Draft EIS. We note that the exact locations for

treatments have yet to be determined, and the Draft EIS states that net effects of the project on

greenhouse gases is unknown given carbon sequestration from forest regeneration and vegetation

growth. The Draft EIS references the Council on Environmental Quality (CEQ) December 2014 Revised

Draft Guidance for Federal Agencies’ Consideration of GHG Emissions and Climate Change. We

believe the Draft Guidance offers a reasonable approach for conducting analyses of GHGs and climate

change impacts. This approach allows an agency to present the environmental impacts in clear terms and

with sufficient information to make a reasoned choice between the no-action and alternatives and

mitigation. We note that the Draft EIS compares the GHG emissions to state and national emissions; we

believe this approach does not provide meaningful information for a planning level analysis. We

recommend that the NEPA analyses provide a frame of reference, such as an applicable federal, state,

tribal or local goal for GHG emission reductions, and discuss whether the emissions levels are consistent

with such goals.

3) Other Considerations

Site-Specificity of Analysis: To the extent possible, we recommend including as much site-specific project

information in the NEPA documentation that is known at the time of the Final EIS. This would include maps

of specific locations identified for various types of treatments, including prescribed fires and landscape

thinning, so that project effects would be more accurately analyzed. This may assist with minimizing the risk

of future NEPA documentation if it’s necessary to revise the analysis based on changes in project design. At

a minimum, we recommend that the Final EIS include maps that specify these types of treatments in

opportunity areas.

Preferred Alternative: The Draft EIS does not identify the lead agency’s Preferred Alternative. As required

under Section 1502.14 of the Council on Environmental Quality’s Regulations for Implementing the

National Environmental Policy Act, unless another law prohibits expression of such a preference, the

Preferred Alternative will need to be identified in the Final EIS. This will ensure that the public will have an

opportunity to comment on the selection of the Preferred Alternative during the Final EIS review rather than

through the USFS objection processes. Although lead agencies are not required to analyze the final decision

on an alternative (i.e., per the ROD), it seems reasonable and judicious to include such an analysis in the

Final EIS if the draft decision is known at that time. We recommend that the USFS’ Preferred Alternative is

clearly described in the Final EIS, or an explanation be provided as to why it is not identified.

Special-Status and Threatened and Endangered Species: The project area may contain special status

species, including Endangered Species Act listed threatened species, endangered species, and/or their

designated critical habitat, as well as candidate species. These include Gunnison sage-grouse, Mexican

spotted owl, Southwestern Willow Flycatcher, Yellow-billed cuckoo, Uncompahgre Fritillary butterfly,

Black-footed ferret, and the Canada Lynx. We recognize that the USFS will discuss the Preferred

Alternative if it differs from the currently proposed action alternatives with the USFWS as it relates to

potential impacts to these species if present in the project area. To best inform the decision-maker and

7

the public, we recommend the NEPA documentation include any USFWS recommendations to reduce

potential impacts to these species including project design criteria, mitigation, conservation measures

and monitoring measures. The results of the USFWS discussions and subsequent recommendations will

be a valuable addition to the Final EIS.

Closing

Consistent with Section 309 of the CAA, it is the EPA’s responsibility to provide an independent review

and evaluation of the potential environmental impacts of this project. Based on the procedures the EPA

uses to evaluate the adequacy of the information and the potential environmental impacts of the

proposed Project, the EPA is rating the Draft EIS as Environmental Concerns – Insufficient Information

(EC-2). The “EC” rating indicates that the EPA review has identified environmental impacts that need to

be avoided in order to fully protect the environment. The “2” rating indicates that the EPA has identified

additional information, data, analyses, or discussion that we recommend for inclusion in the Final EIS.

Because a Preferred Alternative was not identified in the Draft EIS, each of the action alternatives are

receiving an EC-2 rating (we do not rate the no action alternative). A description of the EPA’s rating

system can be found at: http://www.epa.gov/compliance/nepa/comments/ratings.html.

Although the action alternatives received an EC-2 rating in this review, we do not view them as

equivalent based on the Draft EIS analysis. As outlined above, the opportunity areas increase in size

from Alternative 3 to Alternatives 2 and 4. In Alternative 3, fewer roads would be constructed than in

Alternatives 2 and 4. Alternative 3 has a maximum potential estimate of 70 miles of temporary roads

and 10 miles designed roads compared to Alternatives 2 and 4 that have 260 and 60 respectively;

Alternative 4 has the highest potential for dispersal of road impacts due to the larger affected landscape

for commercial treatments. Consequently, Alternative 3 would have reduced effects to water resources

compared to Alternatives 2 and 4, and Alternative 4 would have increased effects compared to

Alternative 2. Regarding fen wetlands, Alternative 3 would include the fewest number of fens or other

wetlands, where Alternative 4 has the potential to include the greatest number of fens and other wetlands

within commercial treatment areas. Commercial mechanical treatment is restricted to suitable timber

lands, which is on slopes <40%. This increases the chance for conflict with fens and wetlands, which

occur on shallower slopes.

We appreciate the opportunity to participate in the review of this project, and are committed to working

with you as you prepare the Final EIS. If we may provide further explanation of our comments during

this stage of your planning process, please contact me at 303-312-6704, or your staff may contact

Melanie Wasco, Lead NEPA Reviewer, at 303-312-6540.

Sincerely,

Philip S. Strobel

Director, NEPA Compliance and Review Program

Office of Ecosystems Protection and Remediation

EST. 1883

July 28, 2015

MONTROSE COUNTY

BOARD OF COUNTY COMMISSIONERS

317 South 2 nd Street

Montrose, CO 81401

Phone: 970-249-7755

Fax: 970-249-7761

Scott Armentrout

Forest Supervisor

Grand Mesa, Uncompahgre, Gunnison NF

2250 Highway 50

Delta, Colorado 81416

SUBMITTED ELECTRONICALLY AND VIA CERTIFIED MAIL

Re: Draft EIS - SBEADMR Project

Dear Scott,

As you are aware, Montrose County has been an active participant in the SBEADMR process

since the original NOI was issued in July of 2013. We continue to support the project goals of

resiliency, recovery and public safety. We thank the GMUG and other Forest Service staff for

the tremendous amount of work that has been completed in order to bring the project to this

point.

The following comments are specific to the Draft EIS (DEIS) . We hope that the Forest Service

will consider taking action on these comments including incorporating suggestions into the Final

EIS and Record of Decision.

1. We appreciate that the Forest Service has maintained a consistent acreage total for

treatment in the 70,000 to 120,000 acre range throughout the proposed alternatives. We

request that no reduction be made in the total acreage proposed for treatment in any of the

proposed alternatives . As noted in the DEIS, the proposed treatment area is already very

small relative to both the overall GMUG land base AND the spruce-fir and aspen cover

types. As stated in the DEIS, "SBEADMR would treat a maximum of 4% of the GMUG,

or approximately 8% of aspen and spruce-fir on the landscape." (Page 196). Any further

reduction in the area to be analyzed would diminish the return on Forest Service

investment and project efficacy.

Page 1

2. With regard to Alternative 3, we are concerned that limiting opportunities for commercial

treatment to the 164,000 acres of suitable timber within the opportunity area may not

produce viable timber sales. Limiting the proposed 40,000 to 60,000 acres of commercial

treatment to a more finite (164,000 acre) area would reduce flexibility for site selection

and incorporation of adaptive management in future project actions. The larger

opportunity areas and potential acreages for commercial treatment identified in

Alternatives 2 and 4 would better serve project targets and avoid conflict that could arise

from directing commercial treatments into a smaller area. We suggest that the Forest

Service expand the opportunity area for Alternative 3.

3. The DEIS states, "The GMUG contains approximately 223,000 cumulative acres of

spruce beetle mortality and 229,000 cumulative acres of affected aspen accumulated over

the past decade, which corresponds to approximately 30% of spruce-fir and aspen on the

GMUG." (Page 261). We continue to be concerned about the length of the project

timeline as compared to the spread of the beetle epidemic and associated spruce/fir

mortality. As noted in the DEIS, "Most (>90%) of mature over-story trees are dying from

beetle infestation in affected areas, usually within 18 months to 2 years." (Page 10).

When considering the limited timeframe (3-5 years) for salvaging merchantable timber

from affected stands, it is clear that any delay in the completion of the project and

offering of subsequent timber sales could result in salvage/commercial treatment targets

becoming unobtainable. Failure to meet these targets would; represent a waste of the

tremendous resources expended on the DEIS, result in substantial increases in future

treatment costs and deprive the public of significant economic benefit.

4. We remain supportive of the use of resiliency treatments within the project. We are

concerned that the scale of the outbreak compared to the size of the treatments may

reduce the efficacy of resiliency treatments as compared to commercial salvage.

Accordingly, in preparing and implementing proposed treatment methods we request that

commercial salvage treatments be given priority over all other treatment methods

(including non-mechanical). This prioritization would be an efficient use of Forest

Service labor and would address the need to access merchantable timber quickly.

5. The DEIS states, "the Forest is proposing and analyzing treatments of a maximum of

120,000 acres, or 4% of the GMUG, in approximately equal proportions between

commercial and noncommercial treatments ." (Page 38). This proportion is consistent

across all of the action alternatives.

To the extent possible, we request that the Forest Service consider expanding the

proportion of analyzed acreage available for commercial treatments within the 120,000

acres of total treatment area. Increased utilization of commercial treatments would lower

treatment costs and provide additional flexibility in adaptive future management over the

8-12 year project period . Any commercial treatments would still need to achieve project

objectives and meet design criteria as proposed .

6. In the interest of public safety and to allow for safe management of fire on the landscape,

we request revisions to "Hazard Tree Removal " as outlined on page 45. Revised language

should specify that mechanical and non-mechanical fuels management activities shall be

conducted within a half mile buffer (quarter mile both sides) of roads open to the public

and other identified infrastructure. Such revisions are necessary to address increased fire

behavior and severity that has recently been observed in beetle killed spruce/fir.

In reference to beetle-affected stands, the DEIS notes, "field observations during fires

suggest these stands experience increased probabilities of torching, crowning and

spotting." (Page 181). A primary example of this behavior is the West Fork Complex on

the Rio Grande National Forest in 2013. We encourage the Forest Service to take the

behavior of the West Fork fire into account when considering buffers for public safety in

the Final EIS.

7. We request that "visually sensitive areas" not be automatically excluded from mechanical

treatment as currently stated on page 46. Widespread tree mortality in both aspen and

spruce/fir cover types will adversely impact visual aesthetics of the forest. Therefore,

limiting treatment in these areas would not improve aesthetics , but would limit ability to

treat in certain areas. In fact the DEIS notes, "Removing dead and diseased trees in

affected spruce stands via recovery treatments would allow existing advanced

regeneration to grow faster with less competition for light and moisture, which would

improve scenic quality over the long-term." (Page 445).

8. To the extent feasible, we request that trees removed through non-commercial

mechanical treatment be made available to the public as firewood. Montrose County is

willing to partner with the Forest Service in order to facilitate this process.

9. The DEIS states, "Of these 278,000 acres commercial opportunity acres, 99,000 acres are

identified as spruce; 97,000 acres as aspen; and 82,000 acres as aspen-spruce mix. As

noted above, commercial aspen treatments are not likely due to the lack of an aspen

market at the time of this writing. " (Page 51).

Given the known market for spruce/fir and the limited market for aspen, we request that

the Forest Service increase the percentage of spruce or spruce/fir made available within a

designated commercial opportunity area in Alternative 2. Even if the geographic location

of the commercial opportunity area is altered the total acreage of the area (278,000 acres)

could remain the same. By necessity , aspen treatments will need to be non-commercial

and therefore a smaller percentage of aspen included in the commercial opportunity area

would not adversely impact project goals.

10. The DEIS states, "Non-commercial treatments would occur outside suitable lynx habitat,

with the exception of hazard tree treatments proximal to infrastructure and fuel treatments

within 200 feet of infrastructure." (Page 51). As noted in comment #6 above, we have

concerns that this distance may not be adequate to protect the public and firefighter safety

during a severe wildfire. We request considering a larger buffer as noted in our comment

#6.

11. With regard to "TSHR-1" it would be more practical to restore/improve roads after heavy

use. Bonding or other means could be used to provide acceptable surety for required

work related to project impacts. (Page 124).

12. The DEIS states, "County road maintenance could result in additional impacts to

individuals such as crushing, or removal by road maintenance equipment." (Page 219).

We feel that this comment is based on an inaccurate assumption that road work conducted

by the County would not be performed to the same standards as work done by the Forest

Service or Forest Service contractors. Montrose County and other GMUG counties are

fully capable of complying with design criteria and environmental safeguards in the

same manner as any other entity performing the work. We respectfully request that this

statement and the anticipated impact be removed from the Final EIS.

13. The DEIS states, "Fens are frequently located in areas with slopes less than 40%, so there

is the potential for greater conflict of treatment placement and effects to fens and their

sensitive species with this alternative." (Page 222).

We disagree with this assumption . Simply because fens occur at slopes of less than 40

percent does not mean that there would be adverse impact associated with Alternative 4.

If properly implemented, the design guidelines and site selection processes in place

throughout the SBEADMR proposal would adequately protect fens and other sensitive

resources regardless of slope.

14. The DEIS states, "ID Team reviews preliminary treatment units and completes project­

specific surveys. Conflicts will be resolved by the District Ranger." (Page C-4). As a

procedural matter we believe it is more efficient to resolve such conflicts at the highest

possible level. Since the proposed action covers the entire GMUG and multiple ranger

districts, we suggest that such conflicts be resolved by the Forest Supervisor or other

regional level staff. This practice would assure consistency of decision making and would

avoid potential conflicts between ID Team members that may be subordinate in the chain

of command to a District Ranger.

15. We suggest that "Estimated Time Since Stand Mortality" be included as a checklist item

under the "Timber Surveys" section on page C-9. The temporal aspect of mortality with

regard to merchantability is critical enough to the overall project that it should be

expressly addressed.

16. The DEIS states, "Because of the 2-3 years needed to plan and implement treatments,

GIS analyses will be focused on potential management adaptations 4-5 years in the

future." (Page E-5). Given the information presented elsewhere in the DEIS and in our

comment #3 above, we are concerned that this processing timeline would preclude stands

which have already been or have recently been affected from being commercially treated.

Therefore, we request the Forest Service consider means to expedite the processing of

commercial treatments .

17. The DEIS "Watershed and Soil Resources" section on page 77 is important to water

quality and quantity in Montrose County and across the Western Slope. We find the

design features to include protections at a project level on page C-3, but we suggest that

this may not capture the need to proactively protect reservoirs and water delivery systems

on public lands. This is of immense importance as Colorado develops a water plan and it

may require a checklist item to address benefits of timber treatments to reduce wildfire

severity and protect water resources. Our agriculture community and Project 7 Water

supply will depend on this.

18. The DEIS "Appendix C - Pre-Treatment Checklist", section 6 does not give specifics

under Socio-Economics. We suggest that the timber section on page C-18 assess the

accountability to meet the timber supply goals found in the Forest Plan. This is perhaps

the intent of the Socio-economic checklist on page C-20. Montrose County is committed

to protecting our natural resource based companies. In 2010-2012, the county dedicated

economic development funds to keep a sawmill in Montrose County. We understand the

vulnerability of this industry as evidenced by the loss of Delta Timber in neighboring

Delta County and believe that this project is economically critical as evidenced in Table

90 on Page 416.

19. The DEIS, "Appendix E: Public Engagement in Adaptive Implementation" refers to

stakeholders and their roles throughout the 10 year process. Given the importance of

continued public involvement in adaptive management, we suggest that a formal,

structured stakeholder group be formed for the purpose of facilitating ongoing public

involvement. The composition of this group should reflect a balanced and diverse

representation from the counties containing GMUG lands.

20. We would like to note that even with staffing and budgetary constraints, Montrose

County was able to conduct a comprehensive review of the DEIS and draft comments

within the timeframe of the original comment period set by the Forest Service. We urge

the Forest Service to use any procedural options available to avoid future attempts to stall

completion and implementation of this critically important proposed action.

Respectfully,

Chairman

4 7

Glen Davis

Vice Chairman Commissioner

,

SAN MIGUEL COUNTY B O A R D O F C O M M I S S I O N E R S

ELAINE FISCHER ART GOODTIMES JOAN JAY

S ubmitted electronically via www.fs.usda.gov/ goto/SBEADMR_comments

July 31, 2015

Scott Armentrout

Forest Supervisor

Grand Mesa-Uncompahgre-Gunnison National Forest

2250 Highway 50

Delta, CO 81416

Re: SBEADMR Draft EIS Comments

Dear Scott:

Thank you to the agency for this opportunity under NEPA for local government to

comment on the SBEADMR draft EIS.

We very much appreciated your working with the Public Lands Partnership to do

initial scoping through a working group process and to collaboratively engage

various stakeholder groups to achieve better understanding of the Forest Service's

proposal and intentions.

However, we are deeply disappointed that the on-going adaptive management

process outlined in the draft EIS does not include a stakeholder FACA committee to

continue the collaboration process through the life of the ten-year project -- as many

of us had been led to believe at the start of the scoping.

There are a number of environmental concerns about regeneration, fire, windthrow,

lynx habitat and lots of site-specific issues that we were hoping would be addressed

by this long-term collaborative advisory group. But without that process, we are

worried.

We support the agency's seeking flexibility to deal with the insect outbreaks and to

make some economic use of salvage trees. But we don't think the agency has

established enough trust with various stakeholder groups to allow a blanket, ten­

year program without more analysis and NEPA process, unless a stakeholder

advisory council is part and parcel of the adaptive management program for

SBEADMR.

P.O. BOX 1170 • Telluride, Colorado 81435 • (970) 728-3844 • FAX (970) 728-3718

Many of us thought this was going to be a ground-breaking push on the part of the

Forest Service to do things differently. But instead, from the draft EIS, it appears that,

yes, there will be "adaptive management" promised by the agency but without real

community buy-in or long-term participation.

The draft EIS seems to set up the "trust-us-we're-professionals " attitude towards the

community that we were hoping we'd gone beyond.

Various "stakeholder opportunity" slots are identified, but it appears that no

organized group advisory process is established. We think this is a mistake and

suggest, instead, that you establish an inclusive, knowledgeable core group of

stakeholders to follow this process through. The "stakeholder opportunity" option

will make it impossible to establish continuity necessary for stakeholders to be truly

involved. As presented, new people will continually join the process, who will have

to get up to speed and ·be re-educated at each opportunity slot. A better option would

be to establish a dedicated group of representatives involved from the beginning

who can help shape issues and solutions as part of the adaptive management

process.

While we think this project has a lot of merit, without a formal advisory group

process to involve stakeholders at each step along the way, we cannot support it.

Regretfully,

SAN MIGUEL COUNTY

BOARD OF COMMISSIONERS

2